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2017 (11) TMI 1194 - AT - Income TaxEligibility for deduction u/s.80IC - whether the assessee is carrying on any manufacturing activity at Dehradun unit? - Held that:- The expenses debited in the Profit & Loss A/c which are re-produced for the AY 2010-11 and 2011-12 clearly indicates that no substantial manufacturing activity was carried out by the assessee from the Dehradun unit. Out of the total expenses incurred on power ₹ 28,50,372/- the Chennai unit has accounted for a sum of ₹ 28,04,127/- and Dehradun unit is ₹ 46,245/- which clearly shows no manufacturing activity is being done at Dehradun unit. Similarly other production expenses accounted for in Dehradun unit were meager or nominal compared to Chennai unit, though the assessee is declaring huge sales from the Dehardun unit and compared to Chennai unit. Therefore we are of the considered opinion that the assessee is not carrying on any manufacturing activity in Dehradun Unit and the Hon’ble ITAT’s Order in the assessee’s own case for the AYs 2007-08 & 2008-09 is squarely applicable. Since we do not find any difference in the facts of the case we hold that the assessee is not carrying on substantial manufacturing activity in Dehradun unit and not entitled for deduction u/s.80IC and uphold the orders of the Ld.CIT(A). - Decided against assessee.
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